Aspire Sussex Student Privacy Notice

About this document

This privacy notice explains how Aspire Sussex Ltd (“we”, “our”, “us”) collects, uses and shares your personal data, and your rights in relation to the personal data we hold. This privacy notice concerns our processing of personal data of past, present and prospective students of Aspire Sussex Ltd (“you”, “your”).
Aspire Sussex Ltd is the data controller of your personal data and is subject to the Data Protection Act 1998 (“DPA”) and to the General Data Protection Regulations (the “GDPR”)).

How we collect your information

We may collect your personal data in a number of ways, for example:
• from the information you provide to us when you interact with us before joining a course, for example when you express your interest in studying at Aspire Sussex Ltd;
• when you apply to study at Aspire Sussex Ltd and complete enrolment forms via web enrol and when you complete other enrolment processes and assessments;
• when you communicate with us by telephone, email or via our website, for example in order to make enquiries or raise concerns;
• in various other ways as you interact with us during your time as a student of Aspire Sussex Ltd, for the various purposes set out below;

The types of information we collect

We may collect the following types of personal data about you:
• your name, and contact information such as address, email address and telephone number, as well as your date of birth, national insurance number (or other tax identification number) and your passport number. We will also allocate you a unique student number;
• information relating to your education and employment history, the courses you have completed, dates of study and examination results. We will also keep records relating to assessments of your work, details of examinations taken, your predicted and actual examination grades and other information in your individual learner record;
• information about your family or personal circumstances, and both academic and extracurricular interests, for example where this is relevant to the assessment of your suitability to receive a concession or in order to provide you with appropriate pastoral care;
• sensitive personal data and information about criminal convictions and offences, including:
• information concerning your health and medical conditions (e.g. disability and dietary needs);
• certain criminal convictions; and
• information about your racial or ethnic origin; religion or similar beliefs; and sexual orientation and
• financial information and bank details

How we use information about our students

The purposes for which we may use personal data (including sensitive personal data) we collect during a student’s association with us include:
• recruitment and enrolment;
• academic matters, including:
– the provision of our core teaching, learning and assessment services (e.g. registration, assessment, attendance, managing progress, certification, destination and progression);
– maintaining student records;
– assessing your eligibility for bursaries, hardship funding or concessions;
• non-academic matters in support of our core services, including:
– providing student support services (e.g. Disability and Additional Learning Support; Information, advice and guidance);
– monitoring equal opportunities;
– safeguarding and promoting the welfare of students;
– ensuring students’ safety and security;
– managing the use of social media;
• administering finance (e.g. fees,);
• other administrative purposes, including:
– carrying out research and statistical analysis;
– carrying out audits (e.g. to ensure compliance with our regulatory and legal obligations);
– providing operational information (e.g. providing IT support, information about building closures or access restrictions on campus, or safety advice);
– promoting our services
– dealing with grievances and disciplinary actions;
– dealing with complaints and enquiries.

The basis for processing your information and how we use it

We may process your personal data because it is necessary:
• for the performance of a contract with you or in order to take steps at your request prior to entering into a contract
• for us to carry out legally required duties
• for us to carry out our legitimate interests
• for us to protect your interests

We may also use your personal data for the following:
• to interact with you before you are enrolled as a student, as part of the enrolment process (e.g. to send you a brochure or answer enquiries about our courses);
• once you have enrolled, to provide you with the services as set out in our Student Handbook;
• to deal with any concerns or feedback you may have;
• to assess the quality of our services
• to meet the statutory duties placed upon us for DfE data collections
• to provide you with educational services
• to monitor and evaluate the performance and effectiveness of Aspire Sussex Ltd, including by training our staff or monitoring their performance
• to maintain and improve the academic, corporate, financial, estate and human resource management of Aspire Sussex Ltd
• to promote equality and diversity throughout Aspire Sussex Ltd
• to seek advice on our rights and obligations, such as where we require our own legal advice;
• recovering money you owe to us
• for fundraising purposes
• to meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws and safeguarding requirements
• for the prevention and detection of crime
• in order to assist with investigations (including criminal investigations) carried out by the police and other competent authorities
• to protect your or another person’s vital interests (safeguarding or Prevent duties)

We may also process your personal data for other reasons where we have your specific or, where necessary, explicit consent to do so.

Sharing information with others

Personal data (including success and qualification data) may be shared with our funding body and prime contract holder West Sussex County Council, with other funding bodies and with organisations we partner with to deliver our courses and services.
We may also share your personal data with other third parties including:
• internal and external auditors
• those with an interest in tracking student progress and attendance, including:
– current or potential employers (to provide references and, where students are sponsored by their employer and/or where you take part in a placement, to provide details of progress/attendance)
– professional and regulatory bodies (e.g examination boards) in relation to the confirmation of qualifications, professional registration
– crime prevention or detection agencies (e.g. the police, the Department for Work and Pensions and Trading Standards)

National Student Survey and Leaver Surveys

From time to time we issue surveys about our provision. You have the option to opt in to receive most of these surveys including the National Student Survey. It is, however, a requirement of your participation on a subsidised course that you complete our leaver survey.

Within six months of completing a course, we will contact each student to ask him or her to respond to a Destination of Leavers questionnaire. Students may also be contacted as part of an audit to check that we have undertaken this survey properly.

How long your information is kept

Subject to any other notices that we may provide to you, we may retain your personal data for a period of seven years after your association with us has come to an end.

Your rights

Under GDPR you have the following rights:
• to obtain access to, and copies of, the personal data that we hold about you
• to require that we cease processing your personal data if the processing is causing you damage or distress;
• to require us not to send you marketing communications
• to require us to correct the personal data we hold about you if it is incorrect
• to require us to erase your personal data
• to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal)
• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller
• to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

If you have given your consent and you wish to withdraw it, please contact our Data Controller using the contact details set out below. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.

Contact us

If you have any queries about this privacy notice or how we process your personal data, or to request access to the personal data that we hold about you, you may contact our Data Controller by emailing data.contoller@aspiresussex.org.uk

If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner.

You can find out more about your rights under data protection legislation from the Information Commissioner’s Office website available at: www.ico.org.uk.

You may also wish to read our website privacy notice https://www.aspiresussex.org.uk/privacy-policy/ or our Data Subject Access process https://www.aspiresussex.org.uk/data-subject-access-and-the-data-protection-act/

Last updated – July 2018